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 requests for change in annual accounting period where the Service has provided an administrative procedure for obtaining a change in annual accounting period. See Rev. Procs. 2000–11, 2000–3 I.R.B. 309 (certain corporations); 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 oth

2001–1 I.R.B. 119 January 2, 2001

erwise provided in the listed revenue procedures, all requests for change in method of accounting where the Service has provided an administrative procedure for obtaining a change in method of accounting. See Rev. Proc. 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), as modified and amplified by Rev. Proc. 2001–10, 2001–2 I.R.B. 272 (qualifying taxpayers with average annual gross receipts of $1 million or less seeking to change from an accrual method to the cash method or from an inventory method to a method complying with § 1.162–3, this revenue procedure is effective for taxable years ending on or after December 17, 1999, and was released to the public on December 6, 2000), Rev. Proc. 2000–50, 2000–52 I.R.B. 601 (taxpayers seeking to change their treatment of certain computer software costs), Rev. Proc. 2000–38, 2000–40 I.R.B. 310 (certain taxpayers seeking to change to any of the three permissible methods of accounting for distributor commissions prescribed in Rev. Proc. 2000–38), Rev. Rul. 2000–7, 2000–9 I.R.B. 712 (certain taxpayers seeking to change their method of accounting for removal costs to conform with the holding in Rev. Rul. 2000–7), Rev. Rul. 2000–4, 2000–4 I.R.B. 331 (certain taxpayers seeking to change their method of accounting for ISO 9000 certification costs to conform with the holding in Rev. Rul. 2000–4), and Notice 2000–4, 2000–3 I.R.B. 313 (certain taxpayers seeking to change their method of accounting for depreciation of MACRS property acquired in a transaction to which § 1031 or § 1033 applies); Rev. Proc. 98–58, 1998–2 C.B. 710 (certain taxpayers seeking to change to the installment method of accounting under § 453 for alternative minimum tax purposes for certain deferred payment sales contracts relating to property used or produced in the trade or business of farming); Rev. Proc. 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); Rev. Proc. 92–67, 1992–2 C.B. 429 (certain taxpay

ers with one or more market discount bonds seeking to make a § 1278(b) election or a constant interest rate election); Rev. Proc. 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 Rev. Proc. 91–51, 1991–2 C.B. 779 (certain taxpayers under examination that sell mortgages and retain rights to service the mortgages).

.03 Section 461.—General Rule for Taxable Year of Deduction.—All requests for making or revoking an election under § 461 where the Service has provided an administrative procedure for making or revoking an election under § 461. See Rev. Proc. 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).

.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, 1998–2 C.B. 643. .05 Sections 1502, 1504, and 1552.— Regulations; Definitions; Earnings and Profits.—All requests for waivers or consents on consolidated return issues where the Service has provided an administrative procedure for obtaining waivers or consents on consolidated return issues. See Rev. Procs. 91–71. 1991–2 C.B. 900 (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).