SECTION 6. AUDIT PROTECTION

FOR TAXPAYERS CURRENTLY USING THE DEFERRAL METHOD

If a taxpayer uses the Deferral Method described in section 5.02 of this revenue procedure for advance payments (as defined in section 4 of this revenue procedure), the taxpayer’s method of accounting for such advance payments under the Deferral Method will not be raised as an issue by the Service in a taxable year that ends before [insert date of publication of final revenue procedure]. If the taxpayer uses the Deferral Method described in section 5.02 of this revenue procedure, and the

treatment of advance payments (as defined in section 4 of this revenue procedure) under the Deferral Method is an issue under consideration (within the meaning of section 3.09 of Rev. Proc. 2002–9) in examination, in appeals, or before the U.S. Tax Court in a taxable year that ends before [insert date of publication of final revenue procedure], that issue will not be further pursued by the Service.