SECTION 1. PURPOSE

This revenue procedure informs taxpayers of the information they must submit to request a closing agreement under §1.1503–2(g)(2)(iv)(B)(2)(i) to prevent the recapture of dual consolidated losses (DCLs) upon the occurrence of certain triggering events.

Before this revenue procedure, the Internal Revenue Service and the Department of the Treasury had not specified in detail how taxpayers should request these

October 23, 2000 394 2000–43 I.R.B.

closing agreements. The Service and Treasury are issuing this revenue procedure to provide taxpayers with guidance on the information and representations they should include in a §1503(d) closing agreement request and to facilitate the process and reduce the time necessary for the Service to process requests.

Appendix A to this revenue procedure is a model closing agreement. The Service intends the model closing agreement to serve as an example of the format and contents of a §1.1503–2(g)(2)(iv)(B)(2)(i) closing agreement and to aid taxpayers in understanding how the information required by this revenue procedure will be used in the closing agreement. Taxpayers should note, however, that the model agreement is only an example. A taxpayer’s actual agreement could differ from the model. Finally, Appendix B is a flow chart of the entities included in the model closing agreement, along with notes explaining the model agreement.