ADMINISTRATIVE

T.D. 8939, page 899. Final regulations under section 6212 of the Code define a taxpayer’s last known address as the address on the taxpayer’s most recently filed and properly processed federal tax return, unless the taxpayer provides clear and concise notification of a different address to the IRS. The final regulations also authorize the Commissioner to use an address obtained from the United States Postal Service National Change of Address database as a taxpayer’s last known address.

REG–110659–00, page 917. Proposed regulations address the adoption of a plan of liquidation requirement under section 332 of the Code when an association makes an entity classification election to be treated as a partnership or disregarded as an entity separate from its owner.

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Notice 2001–22, page 911. Installment sales; changes in method of accounting. This notice provides that an accrual method taxpayer that entered into an installment sale on or after December 17, 1999, and filed a federal income tax return by April 16, 2001, reporting the sale on an accrual method has the consent of the Secretary to revoke its effective election out of the installment method. The taxpayer must file, within the applicable period of limitations, amended federal income tax returns for the taxable year in which the installment sale occurred, and for any other affected taxable year, reporting the gain on the installment method. Notice 2000–26 modified.

Notice 2001–23, page 911. Business expenses; changes in method of accounting. This notice modifies Rev. Rul. 2001–4, 2001–3 I.R.B. 295, which holds, in part, that costs incurred by a taxpayer to perform work on its aircraft airframe as part of a heavy

maintenance visit generally are deductible as ordinary and necessary business expenses under section 162 of the Code. Rev. Rul. 2001–4 is modified by extending the application of the automatic consent for change in accounting method provisions of Rev. Proc. 99–49, 1999–2 C.B. 725, to the taxpayer’s first or second taxable year ending after December 21, 2000. Rev. Proc. 99–49 and Rev. Rul. 2001–4 modified.

Rev. Proc. 2001–25, page 913. Automatic accounting method change for stated inter- est on short-term loans. This procedure modifies section 13.02 of the Appendix to Rev. Proc. 99–49, 1999–2 C.B. 725, 757, to allow any bank that uses the cash receipts and disbursements method of accounting to change automatically its method of accounting for stated interest on shortterm loans made in the ordinary course of its business. Rev. Proc. 99–49 modified.

March 19, 2001 2001–12 I.R.B.