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, 2000–1 C.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 otherwise 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, 1999–2 C.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. 2001–46, 2001–37 I.R.B. 263 (certain taxpayers seeking to change their method of accounting for railroad track structure expenditures to the track maintenance allowance method provided in Rev. Proc. 2001–46), Rev. Proc. 2001– 25, 2001–12 I.R.B. 913 (certain taxpayers seeking to change their method of accounting for stated interest on shortterm loans made in the ordinary course of business), Rev. Proc. 2001–24, 2001–10 I.R.B. 788 (certain taxpayers seeking to change their method of accounting for cash advances on commissions paid to their agents), Rev. Proc. 2001–23, 2001–10 I.R.B. 784 (certain taxpayers seeking to change their method of accounting to the Used Vehicle Alternative LIFO Method provided in Rev. Proc. 2001–23), 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

2002–1 I.R.B 125 January 7, 2002

unless the collection of information displays a valid control number.

The collections of information in this revenue procedure are in sections 3.01(30), 3.02(1) and (3), 4.01(31), and 4.02(1) and (7)(b). This information is required to evaluate whether the request for a letter ruling or determination letter is not covered by the provisions of this revenue procedure. The collections of information are required to obtain a letter ruling or determination letter. The likely respondents are business or other for-profit institutions.

The estimated total annual reporting and/or recording burden is 90 hours.

The estimated annual burden per respondent/recordkeeper varies from 15 minutes to 3 hours, depending on individual circumstances, with an estimated average burden of 2 hours. The estimated number of respondents and/or recordkeepers is 45.

The estimated annual frequency of responses is on occasion.

Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by § 6103.

DRAFTING INFORMATION

The principal author of this revenue procedure is Graham L. Barron of the Office of Associate Chief Counsel (Corporate). For further information about this revenue procedure, please contact Mr. Barron at (202) 622–7790 (not a toll-free call).

out of certain exemptions from dealer status for purposes of § 475); Rev. Proc. 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); 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 corpora

tions 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). .06 Section 704(c).—Contributed Property—Requests from Qualified Master-Feeder Structures, as described in section 4.02 of Rev. Proc. 2001–36, 2001–23 I.R.B. 1326, for permission to aggregate built-in gains and losses from contributed qualified financial assets for purposes of making § 704(c) and reverse § 704(c) allocations.