SECTION 8. OPTIONAL

SETTLEMENT FOR TAXPAYERS UNDER EXAMINATION, BEFORE AN AREA APPEALS OFFICE, OR BEFORE THE TAX COURT

.01 In General .02 Terms of Settlement .03 Procedures for Requesting the Settle-

ment (1) Initiating the request (2) Statement of facts, law, and ar-

guments (3) Perjury statement .04 Procedures for Processing the Re-

quest (1) Receipt of request acknowledged (2) Factual development (3) Acceptance (4) Notification of acceptance .05 Procedures for Implementing the

Settlement (1) Closing agreement or other ap-

propriate settlement agreement required (2) Contents of closing agreement or

other appropriate settlement agreement (3) Review and execution of clos-

ing agreement or other appropri- ate settlement agreement (4) Amended returns (5) Application of Rev. Proc. 2002–18

tenance allowance method”). This revenue procedure also provides procedures for a qualifying taxpayer to obtain automatic consent from the Commissioner of Internal Revenue to change to the track maintenance allowance method, including rules relating to the limitations, terms, and conditions the Commissioner deems necessary to make the change. In addition, this revenue procedure provides an optional procedure for a qualifying taxpayer whose treatment of track structure expenditures is an issue under consideration in examination, before an area appeals office, or before the United States Tax Court (“Tax Court”) to settle open taxable years using the track maintenance allowance method.