SECTION 7. CHANGE IN METHOD

OF ACCOUNTING

.01 Limitations, Terms, and Condi- tions . A change to the CCR method provided by this revenue procedure will be treated as a change in method of accounting to which the provisions of §§ 446 and 481 and the regulations thereunder apply. Therefore, a taxpayer within the scope of this revenue procedure that does not use the CCR method provided in section 5 of this revenue procedure on May 3, 2002, but wants to use this safe harbor method for taxable years ending on or after December 31, 2001, must file a Form 3115. .02 Automatic Change to CCR Method . A taxpayer within the scope of this revenue procedure that wants to change to the CCR method provided by section 5 of this revenue procedure must follow the automatic change in method of accounting provisions of Rev. Proc. 2002–9 (or its successor), as modified by Rev. Proc. 2002–19 (2002–13 I.R.B. 696) with the following modifications:

(1) The scope limitations in section 4.02 of Rev. Proc. 2002–9 do not apply to a taxpayer that wants to make the change for its first or second taxable year ending on or after December 31, 2001;

(2) When filing the Form 3115, taxpayers must complete all applicable parts of the form and, in lieu of the label required by section 6.02(4) of Rev. Proc. 2002–9, are instructed to write “Filed under Rev. Proc. 2002–36” at the top of the form.

.03 Section 481(a) Adjustment . As provided in section 2 of Rev. Proc. 2002–19, the period for negative § 481(a) adjustments is one year, and the period for positive § 481(a) adjustments is four years.

.04 Audit Protection . If a taxpayer complies with the requirements of this revenue procedure and changes its method of accounting for CCR payments to the CCR method provided in section 5 of this revenue procedure, the treatment of CCR payments will not be raised as an issue in any taxable year before the year of change and, if the treatment of CCR payments is already an issue under consideration (within the meaning of section 3.09 of Rev. Proc. 2002–9) in a taxable year before the year of change, that issue will not be further pursued.