Actions Relating to Decisions of the Tax Court
SECTION 3. SCOPE
Internal Revenue Bulletin 2003-18 · 2026-10-03 edition · updated 2026-10-04 · United States
.01 In General . This revenue procedure generally applies to any taxpayer that requests to change the taxpayer’s annual ac
counting period under Rev. Proc. 2002–37 or Rev. Proc. 2002–39.
.02 Prior Accounting Period Changes . This revenue procedure also applies to any taxpayer if:
(1) prior to April 8, 2003, the taxpayer either filed an application for automatic approval to change the taxpayer’s annual accounting period under Rev. Proc. 2002–37 (or any predecessor), or received prior approval to change its annual accounting period by a letter issued by the national office (whether or not issued under Rev. Proc. 2002–39); (2) the administrative procedure, letter ruling, or consent letter under which the taxpayer made the change, as a term and condition of the change, prohibited the taxpayer from carrying back an NOL or CL generated in the short period because the short period was less than 9 months;
(3) the NOL or CL generated in the short period is less than the NOL or CL for the full 12-month period beginning with the first day of the short period; and
(4) the short period necessary to effect the change began on or after February 1, 2000.
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