SECTION 6. AUDIT PROTECTION

FOR TAXPAYERS CURRENTLY USING THE CCR METHOD

A taxpayer within the scope of this revenue procedure that is using the CCR method provided in section 5 of this revenue procedure on May 3, 2002, may continue to use this safe harbor method for taxable years ending on or after May 3, 2002, without filing a Form 3115, Application to Change a Method of Accounting . Such taxpayer’s method of excluding CCR payments from both its gross income and its basis in the purchased vehicle will not be raised as an issue in a taxable year that ends before May 3, 2002. Moreover, if such taxpayer’s method of excluding CCR payments from both its gross income and its basis in the purchased vehicle is already an issue under consideration (within the meaning of section 3.09 of Rev. Proc. 2002–9 (2002–3 I.R.B. 327)) in a taxable

year that ends before May 3, 2002, the issue will not be further pursued.